American trucking company Prime Inc. recently filed a legal complaint in federal court, accusing the Internal Revenue Service (IRS) of misinterpreting tax regulations and claiming that the agency owes it more than $11 million in tax refunds. The full text of the complaint can be found atthe relevant legal document platform.

In the complaint, Prime Inc. stated that it is entitled to an income tax credit for fuel consumed by its trailer refrigeration units. The company believes that, under relevant provisions of the tax code, fuel used for cooling purposes should be considered "non-highway, non-taxable business use" and therefore should not be subject to federal fuel excise taxes.

The company had previously filed refund claims with the IRS for the 2018 to 2021 tax periods. The complaint states that the IRS responded on 2024 and June 11, 2026, respectively, denying its claims and subsequent appeals, and as of the time of filing, had still not made a decision on the claim for the 2021 tax year.

The request for more than $11 million in refunds also includes a request for the federal court to order the IRS to bear attorney fees and other litigation costs, and to grant further relief as the court deems appropriate.

According to the IRS-issuedfuel tax credit guide, in specific business scenarios, if fuel is not used for ordinary driving purposes, such as agricultural use, construction sites, or vehicle use on private property, taxpayers may apply for corresponding tax credits.

The core dispute in this case is whether the fuel consumption of trailer refrigeration units, which operate continuously during transport, falls under the aforementioned "non-highway" use. Prime Inc. argues that refrigeration units do not drive the vehicle, and their fuel use is fundamentally different from highway transportation fuel, so the tax credit provisions should apply.

The IRS, on the other hand, believes that although refrigeration units do not directly drive the vehicle, their operation is closely related to highway transportation activities and may not meet the statutory definition of "non-highway." Currently, the IRS has not yet made a final administrative decision on the 2021 claim, and Prime Inc. has chosen to seek resolution through judicial channels.

If the company wins this case, it will provide an important precedent for the transportation industry on similar fuel tax credit issues. Industry observers noted that such disputes are not uncommon in the cold chain logistics sector, but cases involving such large amounts are relatively rare.

As of press time, the IRS had not made public comments on the matter. Prime Inc., headquartered in Springfield, Missouri, is one of the largest trucking companies in the United States, with operations covering refrigerated transport, flatbed transport, and intermodal services.

The court has not yet scheduled a hearing date. Subsequent developments will depend on whether the IRS files its response within the statutory period and the court's interpretation of the relevant provisions of the tax code.